SEC Company Response from TEVA PHARMACEUTICAL INDUSTRIES LTD (TEVA, TEVJF) (CIK 0000818686) (TEVA) — Apr 16, 2018
TEVA PHARMACEUTICAL INDUSTRIES LTD (TEVA, TEVJF) (CIK 0000818686)
Date: April 16, 2018 · CIK: 0000818686 · Accession: 0001193125-18-118596
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File numbers found in text: 333-224102
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CORRESP 1 filename1.htm Acceleration Letter Teva Pharmaceutical Industries Limited 5 Basel Street P.O. Box 3190 Petach Tikva, 4951033 Israel April 16, 2018 Via EDGAR Submission Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549-3561 Re: Teva Pharmaceutical Industries Limited Registration Statement on Form S-4 (File No. 333-224102) Ladies and Gentlemen: Pursuant to Rule 461 of the Securities Act of 1933, as amended (the “Act”), Teva Pharmaceutical Industries Limited (the “Company”), Teva Pharmaceutical Finance Netherlands II B.V. and Teva Pharmaceutical Finance Netherlands III B.V. (collectively, the “Registrants”) hereby request acceleration of the effective date of its Registration Statement on Form S-4 (SEC File No. 333-224102) (the “Registration Statement”), to 8:00 a.m., Eastern Time, on Thursday, April 19, 2018, or as soon thereafter as possible. The Registrants hereby acknowledge their responsibilities under the Act and the Securities Exchange Act of 1934, as amended, as they relate to the proposed exchange offer of the securities specified in the Registration Statement. U.S. Securities and Exchange Commission April 16, 2018 Page 2 Please contact Ross M. Leff of Kirkland & Ellis LLP, special counsel to the Company, at (212) 446-4947, as soon as the Registration Statement has been declared effective, or if you have any other questions or concerns regarding this matter. Sincerely, Teva Pharmaceutical Industries Limited By: /s/ Deborah Griffin Name: Deborah Griffin Title: Senior Vice President and Chief Accounting Officer Teva Pharmaceutical Finance Netherlands II B.V. By: Teva Pharmaceuticals Europe B.V., its Managing Director By: /s/ David Vrhovec Name: David Vrhovec Title: Managing Director By: /s/ John Nason Name: John Nason Title: Managing Director Teva Pharmaceutical Finance Netherlands III B.V. By: Teva Pharmaceuticals Europe B.V., its Managing Director By: /s/ David Vrhovec Name: David Vrhovec Title: Managing Director By: /s/ John Nason Name: John Nason Title: Managing Director cc: Ross M. Leff Kirkland & Ellis LLP